In the Southern Railway Co. v. Lunsford case of 1935, the Supreme Court ruled in favor of Southern Railway Co., reversing a previous decision by the Circuit Court of Appeals which had awarded damages to Mrs. Lunsford for her husband's death due to alleged negligence on part of the railway company. The court held that there was insufficient evidence presented at trial proving negligence by Southern Railway Co., and thus it could not be held liable for Mr. Lunsford's death under Federal Employers' Liability Act (FELA). The ruling emphasized that while FELA does hold employers accountable for injuries or deaths caused by their negligence, liability cannot be imposed without substantial proof demonstrating such neglectful behavior directly resulted in harm.

In the dissenting opinion for Southern Railway Co. v. Lunsford, it was argued that the majority's decision to uphold a verdict in favor of an injured employee was incorrect due to insufficient evidence proving negligence on part of the employer. The dissenting justices believed that there were no clear indications or proof showing that Southern Railway Company had failed in its duty to provide safe working conditions for its employees, which resulted in Mr. Lunsford’s injuries and subsequent death. They contended that merely because an accident occurred does not automatically imply negligence by the company; accidents can happen even under perfectly safe conditions and procedures if they are not followed correctly by workers themselves. Therefore, without concrete evidence demonstrating how exactly Southern Railway Company breached their duty towards safety measures leading directly to Mr.Lunsford's injury, holding them liable seemed unjustified according to these justices.